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Official guidance
Capital Gains Manual

CG73810P · Non-resident Capital Gains Tax (NRCGT) – disposals from 6 April 2015 to 5 April 2019: companies: special rules

  • CG73810 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Introduction
  • CG73813 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Company's profits for corporation tax purposes to include chargeable gains
  • CG73816 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Reconstruction involving transfer of business
  • CG73819 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Non-resident CGT disposals: roll-over relief
  • CG73822 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Relief for gifts of business assets
  • CG73825 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Gifts to non-residents
  • CG73828 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Gifts to foreign-controlled companies
  • CG73831 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Gifts of UK residential property interests to non-residents
  • CG73834 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Companies migrating from the UK - deemed disposal of UK residential property interest
  • CG73836 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Gifts on which inheritance tax is chargeable
  • CG73838 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Gifts of UK residential property interests to non-residents
  • CG73840 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Pooling of NRCGT gains and losses
  • CG73842 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Elections to join pooling groups
  • CG73844 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Charging non-resident CGT gains of pooling groups
  • CG73847 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Companies joining and leaving pooling groups
  • CG73849 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Obligations of "responsible members" and "representative company"
  • CG73852 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Non-Resident CGT Disposals, Gains and Losses - Special Rules for Companies
  • CG73854 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Indexation
  • CG73857 · Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Computations involving companies, example
  1. Non-resident Capital Gains Tax (NRCGT) – disposals from 6 April 2015 to 5 April 2019: companies: special rules: contents
  2. Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Company's profits for corporation tax purposes to include chargeable gains

CG73813 | Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Company's profits for corporation tax purposes to include chargeable gains

From HM Revenue & Customs · Capital Gains Manual

The 2015 legislation amends the provisions in TCGA92/S8* on taxing gains, and relieving losses, of companies chargeable to corporation tax. The principle that losses may generally be set against CT on a company’s profits is extended, so that unused allowable non-resident CGT losses accruing to the company may be similarly applied.

There are links here to the changes to TCGA92/S2* (see CG73763), which provide for non-resident CGT losses to be computed in the same way as for non-resident CGT gains, and to be available to use against chargeable gains. The amendments to TCGA92/S8* ensure that the treatment of companies is on all fours with that of individuals.

*These sections were re-written for disposals from 6 April 2019 see CG10150

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